BASE HEADER

1) I support all five sites listed as Preferred Options
2) I object to inclusion of site GT11 in the list of Alternative Sites, for reasons stated in my submission to initial consultation of June 2013, as per attached file
3) i reserve the right to submit further comments and/or objections on any listed site(s) prior to any final decisions being made by the Council

SITES FOR GYPSIES & TRAVELLERS, JUNE 2013
SITE GT11 - SUBSTANTIVE OBJECTIONS
I was quite shocked to learn that this land, labelled GT11, adjacent to the Chase Meadow estate, is being considered by the Council for use as a possible large scale permanent site for Gypsies and Travellers (Gypsies and Travellers Sites - Options for Consultation, June 2013, Warwick District Council) in connection with its new Local Plan.
Indeed, there are so many reasons why the use of a large part of this land as a Gypsy and Traveller site cannot possibly fit any rational planning policy criteria that, as a qualified planner, I have to question why it was ever considered in the first instance?
It is hard to know where to start with objections to this proposal but in this detailed submission I set them out in three sections as follows:
 Objections to the Council's approach to needs assessment, which underpins the subsequent site search options.
 Specific objections to site GT11.
 Recommendations for a sustainable approach to site search and assessment, with additional potential sites proposed.
Throughout this submission, 'GTC' refers to Gypsy and Traveller Community; 'the Council' refers to Warwick District Council (WDC); 'the District' refers to Warwick District.
OBJECTIONS TO OVERALL APPROACH
1. Assessment of Accommodation Need - General Approach
The document 'Planning Policy for Travellers Sites', March 2012 is part of the National planning framework and sets out guidance in respect of the government's aims in respect of traveller sites, an extract from which states:
 to ensure that local planning authorities, working collaboratively, develop fair and effective strategies
 that local planning authorities should make their own assessment of need for planning purposes

In addition, the 2011 Localism Act sets out a 'duty to co-operate' in the production of joint development plans on a cross-authority basis, especially where a local planning authority has planning constraints across its area as in Warwick District where the Green Belt covers 81% of its modest 109 square miles, (in comparison Stratford District contains 378 square miles).
However, in respect of the foregoing, the Council admits it has attempted to, but failed to liaise and work with adjacent councils, both in assessment of need and in the identification of suitable sites, and has therefore continued to try and identify land within its own boundaries to serve its own need, ie at a relatively small geographical scale.
Such an approach makes little sense in relation to the GTC, which is by its very nature transient, and where administrative boundaries have little if any, relevance. Thus identification of need and planning of site provision is best carried out at a larger (sub-regional or county) scale in order to be strategic, robust, rational and equitable.
The Council's approach to this issue can therefore be seen to be fundamentally flawed, even at this preliminary stage.
2. Assessment of Accommodation Need - Quantification
Since 2008 there have been a whole series of GTC accommodation needs assessments for permanent pitches the District, with widely varying results.
The original 2008 (South Housing Market) assessment identified a District requirement for 11 permanent pitches, subsequently the Regional Spatial Strategy allocated 23 to the District for the period 2007 - 2017.
However the Council subsequently rejected this figure suggesting it was based on limited evidence and therefore not robust or reliable, and undertook its own assessment which reported in April 2011. This concluded that demand for permanent GTC sites in the area was 'low and transitory in nature' and recommended provision of a 12 pitch transit site only, (15 caravans).
In 2012 the Council appointed consultants from Salford University to carry out a detailed assessment of GTC accommodation needs within the District. Although the final report is quite lengthy, the key figure of 31 permanent pitches (2012 - 2026), is based fairly simplistically on current (2012) unauthorised encampments of 23 pitches (1 pitch = 1 household). However, their separate estimate, from interview survey, of the number of GTC households 'based in the District' was 30, but of these, only 7 were actually living in caravans, the rest were living in bricks and mortar houses!
In view of their wide range, the reliability of all these estimates of GTC permanent pitch need must be questionable.
OBJECTIONS TO SITE GT11
Site Location and Nature
This is a substantial area of search, within which a large site of 12 pitches/19 caravans would be located i.e. approximately 6,400 m2 in area, (at 500 m2 per pitch). Such a site would be expected to accommodate some 45 persons, based on an average GTC household size of 3.7, however it is not unreasonable to take this as a minimum estimate for planning purposes.
Bounded by mature trees to the A4189, it is currently in use as farmland but also contains a spur to the racecourse track and one large residential property. The area is less than 20 metres via the A4189 from the edge of Chase Meadow, a large residential estate of approximately 1,000 dwellings, due to increase to approximately 1,400 when fully developed. Hence present and future population figures of 4,000 and 5,600 respectively can be estimated for the estate at an average of 4 persons per dwelling.
Assessment against Policy Criteria
The suitability of GT11 can partly be determined by assessing the extent to which the site meets, or fails to meet, each of the 10 policy criteria as listed in the Council's document 'Sites for Gypsies and Travellers', June 2013, paragraphs 7.3 and 7.4, as listed in the next section.
It should be noted however that these ten are not necessarily the only or the most appropriate criteria, have not been consulted upon, moreover they do not fully take into account the National guidance ('Planning Policy for Travellers Sites', March 2012), as they omit a key National policy requirement, namely the protection of local amenity - see page 7.
1. Convenient access to a GP surgery, school, and public transport
Whilst access to these may be physically convenient, both the local GP practice on Chase Meadow and both Newburgh Primary and Aylesford schools have no spare capacity, primarily due to existing demand from the resident population of the Chase Meadow and Forbes Estates and from projected future demand from the former - an additional 1,600 persons. Moreover, in the case of the schools, the demand on teaching time and resources from the GTC is likely to be disproportionately greater per pupil than from the settled community, due to the former's well documented special educational needs
CONCLUSION - FAILS
2. Avoiding areas with a high risk of flooding
The site is directly bounded to the east by the Gog Brook and a tributary stream to the north, the former falling within the Environment Agency's Flood Zone 3, hence a measurable risk of flooding is present. (See also under 3. below)
CONCLUSION - FAILS
3. Safe access to the road network and provision for parking, turning and servicing on site
In the vicinity of the site, there is already a high volume of peak time traffic flows along the A4189 Hampton Road with eastbound traffic approaching at relatively high speeds and considerable traffic turning movements from and into the Chase Meadow and Forbes estates. Due to the high levels of GTC vehicle ownership, the proposals for this site would significantly exacerbate traffic congestion by generating additional flows and turning movements, in particular of large, slow moving commercial vehicles, many towing caravans and/or trailers. Moreover, this is a road that is subject to periodic flooding in the vicinity of the racecourse main entrance, and where the road is restricted in width due to parked vehicles along the residential frontage.
CONCLUSION - FAILS on safe access
4. Avoiding areas where there is the potential for noise and other disturbance
The site is subject to significant traffic noise from the adjacent A46. A related issue is the 'noise and disturbance' which might be generated by the resident GTC themselves and so would be likely to adversely affect the amenity of adjacent Chase Meadow residents. CONCLUSION - FAILS
5. Provision of utilities (running water, toilet facilities, waste disposal, etc)
As this is essentially a green field site, there are no utilities present; they would all have to be provided from scratch at considerable cost and higher than that for other brown field equivalents.
CONCLUSION - FAILS
6. Avoiding areas where there could be adverse impact on important features of the natural and historic environment.
This is a sensitive urban fringe location, adjoining the Green Belt boundary at the A46 by pass, and this importance was reflected in its designation by the Council in 2012 as a 'Green Wedge' search area, areas that the Council are committed to protecting in future:
The Council will identify and protect a network of green wedges important for their ecological, landscape and/or access functions in the setting of differing urban areas and urban rural fringe. It is intended that this approach will revise and replace the existing policy of Areas of Restraint in the Local Plan 1996 - 2011.'
(New Local Plan Preferred Options report, May 2012, WDC, paragraph 15.14).
Related to the above, the site lies at a key 'Gateway Route' via the A4189, into the town of Warwick. Despite screening, due to its large scale there would most likely be an adverse visual impact from the perspective of both the racecourse and the A4189. In particular in the case of visitors and coach borne tourists approaching from the east, their first visual impression of Warwick, a town of national historic and cultural importance, would be a large gypsy encampment!
CONCLUSION - FAILS
7. Sites which can be integrated into the landscape without harming the character of the area.
As for 6. above.
CONCLUSION - FAILS
8. Promotes peaceful and integrated co-existence between the site and the local community
Site locations close to existing residential areas are more likely to increase rather than reduce tensions between settled and traveller communities, especially if both are at larger scales as with GT11. This is due to fundamental incompatibilities between the two communities, arising from the nature of the GTC culture, way of life and economic activity, and regardless of whether sites are authorised or not.
There is also evidence that crime and antisocial behaviour increases due to the presence of large numbers of the GTC in a locality.
CONCLUSION - FAILS
9. Avoids placing undue pressure on local infrastructure and services
As for 1. and 3.
CONCLUSION - FAILS
10 Reflects the extent to which traditional lifestyles (whereby some travellers live and work from the same location) thereby omitting many travel to work journeys, can contribute to sustainability
There will be no net increase in 'sustainability' as the same factors already apply to existing unauthorised sites, and all GTC sites will generate many 'travel to work' journeys. Moreover, to the extent that these sites are commercial and industrial in nature as well as residential, this is clearly incompatible with established planning principles of zoning and separation and likely to be detrimental to local amenity and environment. ie detract from 'sustainability'.
CONCLUSION - FAILS
The protection of local amenity is an important consideration in any planning process and a specific requirement of the government's March 2012 guidance for traveller sites: 'for local planning authorities to have due regard to the protection of local amenity and local environment'
It has already been noted this key aspect is not even included in the Council's 10 criteria, and one has to question why - could it be because the Council are fully aware that GTC sites invariably have a detrimental effect on local amenity, and extending beyond the boundaries of the sites themselves?
There have been several large scale unauthorised gypsy encampments in the District in recent years, including locations in Kenilworth, on Warwick Racecourse and on Myton Fields. In all these cases it is on the record that the sites have been left badly littered and degraded when vacated, requiring costly clean up and remediation work, all paid for out of public funds. Similar ongoing negative impacts are likely to be generated with permanent sites, which could affect the amenity of any adjoining residential areas. The larger the sites and the closer to the residential areas, as in the case of GT11, the larger the impacts are likely to be.
CONCLUSION - FAILS
SITE SEARCH AND ASSESSMENT
Site Search and the Green Belt
Twenty options for sites/areas of search are listed, the sizes are not given but many comprise substantial areas. The distribution of these sites within the District is noticeably skewed, with 65% located in the south, 40% immediately west of Warwick and 4 or 20% located within 1 kilometre of a major residential area, Chase Meadow estate
The Council may claim this is due to a need to protect the Green Belt from inappropriate development, but it is also a result of the Council's failure to co-operate with adjoining councils, necessary because it is both small in area, and predominantly Green Belt.
It is important to note at this point that Chapter 9 of the 'National Planning Policy Framework', March 2012, makes it clear that the Green Belt, which covers the northern four fifths of the District, does not represent an insuperable barrier to development; indeed the preparation of a new Local Plan provides opportunities 'to review and adjust Green Belt boundaries and also to identify areas for development' (Paragraph 84).
The Council took on board this National guidance in its Green Belt policy, (New Local Plan Preferred Options report, May 2012, WDC, Chapter 16), which allocated substantive residential and employment development on Green Belt land with associated boundary adjustments. The justification for this Preferred Option was set out in the Housing Chapter of the same report, and although Chapter 16 is silent on GTC sites, it seems logical that they would be permissible on the same grounds as housing. Regrettably, and misguidedly, the Council has now changed its approach to the broad location of growth from that set out in the May 2012 report, and which is now the subject of major but separate objections.
Nevertheless, the March 2012 National Policy Framework still applies and should be taken into account by the Council in the identification of suitable traveller sites, as outlined in the next section.
Site Search Process
As things currently stand, in moving to the next stage of this part of the Local Plan process the Council will need to identify a 'preferred' list of suitable sites, not necessarily from the current options.
How should the Council go about this crucial next stage?
Good access to the trunk road network and locations within reasonable travelling time, say 15 minutes, of major urban areas should be the key initial considerations.
As the GTC have high levels of vehicle ownership, the availability of public transport is a subsidiary issue.
A sequential search process, (a well established planning principle), should then be followed, starting with brownfield sites, (which may already have some infrastructure, utility connections etc), including those close to/adjacent to industrial/commercial land use areas.
Only when the previous stages have been exhausted would it be necessary to consider greenfield sites, some of which may be in the current Green Belt and starting with those close to/adjacent to agricultural/industrial/commercial land use areas.
Only as a final stage, and if necessary, would consideration be given to greenfield sites close to or adjacent to small scale residential areas.
There should be no need in this process to consider sites close to or adjacent to large scale residential areas, with all the conflicts and problems this would be likely to generate. Indeed, a search exclusion zone of at least 1 mile should be applied around such areas. The reason for this is the fundamental incompatibility between the GTC and the settled community, due to the nature of the GTC culture, lifestyle and economic activity, previously referred to.
At each stage, sites can be assessed against the relevant national and local policy criteria.
As an example of a robust and rational approach to site assessment reflecting the above principles, I would commend that recently adopted by Lewes District Council, ('Gypsy and Traveller Site Assessment 2011 - Lewes District Council'), based on a set of 14 criteria, which had been widely consulted on by both the local settled and traveller communities. Sites were scored against each criterion, and subsequently ranked.
One of the criterion was the proximity to large numbers of residential properties, identified as a negative factor, on the grounds that:
'In order to promote understanding and tolerance between local residents/landowners and Gypsies and Travellers, it is important that any impact on the living conditions for local people are acceptable. The number of residential properties in proximity to sites is therefore a factor'
This is yet another very good reason to reject site GT11 on the grounds of its proximity to the large Chase Meadow estate.
Locations Not Yet Considered
There are a number of locations apparently not yet considered by the Council with potential to provide suitable sites, including:
 Castle Park - an extensive tract of land to the south of the town but with no public access
 Various areas of vacant land north of Warwick town centre in the vicinity of the canal, e.g. sites around Lower Cape
 Open fields adjacent to the river/canal/railway line between Warwick and Leamington
 Areas adjacent to Warwick/Leamington southern urban fringe and industrial estates e.g. Gallows Hill, Heathcote Lane, etc
In conclusion, this objections submission clearly shows the perversity of ever including site GT11 in the present options list, a site which demonstrably fails to meet ANY of the relevant national and local policy criteria. Thus, the Council should give no further consideration to this site.
Whilst the Council's underlying approach to this whole GTC sites issue is also shown to be fundamentally flawed, some constructive proposals are put forward in relation to identification of suitable alternative sites.
I rest my case.